Robert Cole Stemkowski Goldman v. Arizona Board of Regents
D. Arizona · Oct 29, 2025
- Jurisdiction
- federal
- Court
- D. Arizona
- Record ID
- robert-cole-stemkowski-goldman-v-arizona-board-of-regents-2025-10-29
- Observed outcome
- The court granted in part and denied in part the motion to dismiss and issued a show cause order regarding potential Rule 11 sanctions.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a show cause order requiring plaintiff's counsel to explain the inclusion of non-existent case law, misattributed quotes, and misrepresented legal precedents in their response brief. The court explicitly linked these errors to the likely use of generative AI and ordered counsel to show cause why they should not be sanctioned under Rule 11.
False Quotes: Case Law | Plaintiff quoted language attributed to Johnson v. City of Shelby that does not appear in that decision; Court notes the quoted text is not in the cited opinion. || Misrepresented: Case Law | Plaintiff relied on Pearson v. Callahan while characterizing it as supporting the opposite proposition; Court explains Pearson actually endorses early resolution of qualified-immunity questions. || Fabricated: Case Law | Plaintiff cited a non-existent Ninth Circuit opinion to support the proposition that qualified-immunity dismissals are premature; Court and defendants could not locate the case and characterized it as hallucinatory.
Misrepresenting precedent is treated like fabrication; verify each holding, not just the citation string.
Failure modes and consequences
- Fabricated_case_law
- Misrepresented_precedent
- Hallucinated_quotes
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- AI attribution
- Implied
- Recorded tool
- Generative AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- The court ruled on a motion to dismiss the plaintiff's amended complaint, dismissing several claims with prejudice while preserving others, and simultaneously issued a show cause order regarding the plaintiff's briefing conduct.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The court identified indicators of generative AI use.
Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Retain a matter-level record of source checks and corrections.